Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
The High Court reviewed an assessment order challenged for being unreasoned. The Court found that the order lacked proper reasoning as it confirmed the tax proposal without explanation, rendering it unsustainable. The order was set aside, and the case remanded for reconsideration. The respondent was instructed to grant the taxpayer a fair opportunity, including a personal hearing, and issue a new order within three months. Consequently, the bank attachment linked to the assessment order was lifted. The petition was disposed of through remand.
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